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Practical Documents For Campus Security: NFPA 730 and 731 By Michael A. Anthony P.E., and Richard J. Davis, P.E. J.D.
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PPA members and higher education leaders should be aware of two NFPA (National Fire Protection Association) documents regarding campus security: one is a “guide” and the other is a “standard.” For the education facilities industry, the differences are important. The standard, NFPA 731, is written in code language, and may be adopted by states and local jurisdictions as such. It is also prescriptive and is essentially a “how to” document. However, the guide, NFPA 730, may be the more important of the two because it may affect campus construction details, manage-
ment planning, and campus liability if it becomes the de-facto leading practice document for campus security. It is the document that explains the scope of security planning, or the “what to” do. Together they are important for the following reasons: • They may become enforceable law if they are adopted by state and local government. • States may reference them in school design guidelines. • They may be adopted by insurance companies or risk managers as property loss prevention programs. • They may be used by plaintiff’s counsel as a standard of care, thereby establishing a duty owed by colleges and university to victims of crime in actions by the victims against the university or college. • They may compete with specialized real estate or build-
ing security interest groups who want the document they produce to be the leading practice document for our industry. With some estimates placing the award for verdicts and settlements in excess of $1.2 million1, APPA’s Code Advocacy Task Force would like to help campuses reduce and manage risks in an environment of appropriate codes and standards. NFPA 730 is much more relevant for campus security than NFPA 1600: Standard on Disaster/Emergency Management and Business Continuity Programs. NFPA 1600 was correctly referenced in a 2009 report by NACUBO titled, “Campus Safety and Security Project.” 2 The article included discussion and information on events that could be viewed as both disasters and security challenges. However, crime is always a security issue but may not rise to the level of a disaster in all cases.
NFPA 730 - Guide on Premises Security. This guide describes construction, protection, occupancy features, and practices intended to reduce security vulnerabilities to life and property. The genesis of NFPA 730 was a request by the insurance industry in 1994 to develop a burglary and security document. The project did not materialize until 2000, when the NFPA Standards Council appointed a committee to develop a premises security document. The starting roster of technical experts delivered NFPA 730 and 731. As a guide, NFPA 730 is advisory or informative in nature and contains only non-mandatory provisions. Although a guide may contain mandatory provisions—not the least of which deal with when and where it applies—the document is not suitable for adoption in its present form by reference in a public statute.
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Another document, Risk Analysis Standard for Natural and Man-Made Hazards to Higher Education Institutions 3 developed by the American Society for Mechanical Engineering (ASME), issued in 2010, is a relatively new document in the campus security space that will be examined by the CATF for applicability to our industry and likelihood of adoption by relevant agencies. Until that time, the documents APPA members need to be watching regarding security are NFPA 730 and 731. Additional information on the work of the Code Advocacy Task Force can be found on the APPA website.4 Summary
Writers of model law documents must always steer their thinking between two extremes: making a consensus document a commercial prospect by creating a general document that can be used and adopted by everyone; versus incorporating extremely specific provisions that may become obsolete quickly and may not be suitable for broad adoption. The outcome can be the document is so general that it is useless in guiding an industry toward practical solutions. NFPA 730 and 731 are not perfect documents. However, they have been developed by the NFPA’s procedures conforming to the American National Standards Institute’s process
for consensus documents and are on solid ground. They can be improved and form a suitable platform for that work. For colleges and universities, the existing structure is useful and worth building upon. References: 1 “NFPA 730 & 731 New Premises Security System Standard Strives to Make the World a Safer Place”, Jim Lardear, NEC Digest, February 2005, National Fire Protection Association, Quincy, MA 2 “Results of the National Campus Safety and Security Project” Report by the National Association of College and University Business Officers (NACUBO), July 2009. http://www.nacubo.org/Documents/ Initiatives/CSSPSurveyResults.pdf 3 Risk Analysis Standards for Natural and Man-Made Hazards to Higher Education Institutions. American Society of Mechanical Engineers Innovative Technology Institute (ASME-IT) - 2010 http://www.asme-iti.org/Initiatives/ Higher_Education.cfm 4 APPA Code Advocacy Task Force Transcripts: http://appa.org/standards.cfm
Mike Anthony is a senior electrical engineer at the University of Michigan. He can be reached at
[email protected]. Richard Davis is the facilities engineer at Evergreen State College and can be reached at
[email protected]. The authors would like to extend their gratitude to Anne Gross at NACUBO for her comments on this article.
NFPA 731 - Standard for the Installation of Electronic Premises Security Systems. This standard covers the application, location, installation, performance, testing, and maintenance of electronic premises security systems and their components.
Proposals for the 2013 revision of NFPA 730 & 731 are due May 24, 2012. Feel free to communicate with anyone on the Code Advocacy Task Force regarding any ideas you would like to contribute to these documents.
By comparison, NFPA 731, a standard, is a document that contains only mandatory provisions, using the word “shall” to indicate requirements, and which is in a form generally suitable for mandatory reference by another standard or code. It may be adopted into law. Non-mandatory provisions are located in an appendix or annex, footnote, or advisory note and are not considered a part of the requirements of the standard. Even though NFPA 730 was not written to be enforceable and is crafted in non-mandatory language, it may have the practical effect of increasing APPA member liability exposure because it is the only document developed according to a true ANSI process that contains a dedicated chapter on security in educational facilities.
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